Conflict Minerals Report for the Calendar Year Ended December 31, 2023
This Conflict Minerals Report contains certain “forward-looking statements” that are based on our current expectations and assumptions. Forward-looking statements by their nature address matters that are, to different degrees, uncertain. Forward-looking statements include any statements that are not historical and include the statements made under the heading “Risk Mitigation.” All forward-looking statements made in this Conflict Minerals Report are based on information currently available to Vertiv Holdings Co (“Vertiv,” “we,” “us,” or “our”) as of the date of this report. Vertiv undertakes no obligation to publicly update or revise any forward-looking statements, whether as a result of new information, future events, or otherwise, except as may be required by law. In addition, forward-looking statements are subject to certain risks and uncertainties that could cause actual results to differ materially from Vertiv’s historical experience and its present expectations. These risks and uncertainties include, but are not limited to, the continued implementation by Vertiv and our direct and indirect suppliers of satisfactory traceability and other compliance measures on a timely basis, or at all.
Vertiv has prepared this Conflict Minerals Report (the “Report”) for the year ended December 31, 2023, consistent with the requirements of Rule 13p-1 of the Securities Exchange Act of 1934, as amended, relating to conflict minerals (the “Rule”). The Rule imposes certain reporting obligations on Securities and Exchange Commission registrants whose manufactured products or products contracted to be manufactured contain conflict minerals which are necessary to the functionality or production of their products. The term “conflict minerals” is defined in the Rule as cassiterite, columbite-tantalite (coltan), wolframite, and their derivatives, tin, tantalum, tungsten and gold (“conflict minerals” or “3TG minerals”); or any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of Congo (“DRC”) or any adjoining country that shares an internationally recognized border with the DRC (the “Covered Countries”). Vertiv’s conflict minerals due diligence and its results for reporting year 2023 are described below. The copy of this Report will be publicly available at https://www.vertiv.com/en-us/about/ethics--compliance/#/tab-supply-chain.
1.Company Overview
Vertiv is a global leader in the design, manufacturing and servicing of critical digital infrastructure technology that powers, cools, deploys, secures and maintains electronics that process, store and transmit data. We provide this technology to data centers, communication networks and commercial and industrial environments worldwide.
Vertiv is headquartered in Columbus, Ohio and has regional offices located in the United Kingdom, Italy, China, India and the Philippines. We have approximately 27,000 employees and sell products to customers worldwide. Our supply chain includes more than 10,000 vendor partners in 115 countries that provide Vertiv with manufactured components, raw materials, software, professional services, logistics support and subcontracted services.
Vertiv’s supply chain is multi-tiered and we are typically many levels removed from mines, smelters and refiners. We do not purchase any 3TG minerals directly from mines, smelters or refiners. Some of Vertiv’s products may contain 3TG minerals either from recycled sources or in their processed form. We rely on our direct suppliers to provide information to us as to the existence of, and the origin of, any 3TG minerals contained in components and materials supplied to us, including the sources of any 3TG minerals supplied to our direct suppliers from their lower-tier suppliers. Direct suppliers to Vertiv similarly typically rely on information provided by their suppliers.
Vertiv is committed to complying with the Rule and upholding responsible sourcing practices. Vertiv has published a Conflict Minerals Statement and built a complex due diligence program so as to ensure responsible sourcing practices in its supply chain. Vertiv’s Conflict Minerals Statement is available at the following link: https://www.vertiv.com/en-us/support/conflict-minerals-statement/. Vertiv’s Conflict Minerals Policy is available upon request.
Vertiv has actively engaged with its customers, suppliers and other stakeholders on the use of conflict minerals and responsible sourcing since the Rule was enacted. Vertiv organized several webinars focused on conflict minerals in order to educate its supply chain on the need for accurate conflict minerals reporting. Vertiv requires that all materials used in its products be preferably sourced from conflict-free smelters or refiners. Further, Vertiv is a member company of the Responsible Minerals Initiative (“RMI”) and requires its suppliers to work with their supply chain to cease sourcing from smelters or refiners that are not designated as conformant or active per the RMI’s Responsible Minerals Assurance Program or are otherwise identified as high-risk.
Vertiv endeavors to comply with applicable conflict mineral regulations. Accordingly, Vertiv monitors updates from the RMI and from the Office of Foreign Assets Control (“OFAC”). In addition to the conflict minerals due diligence discussed herein, Vertiv is committed to ethical, socially responsible and sustainable sourcing other minerals that may be connected to human rights abuses. To that end, Vertiv has established a Cobalt Reporting Program, which aims to identify and minimize risks of connection to human rights abuses, environmental issues and unethical business practices involved with the cobalt mining and processing. Cobalt sourcing information was collected using a standard document created by the RMI—the Extended Minerals Reporting Template (“EMRT”).
2.Reasonable Country of Origin Inquiry
Vertiv has determined that 3TG minerals were necessary to the functionality and production of some of our products manufactured or contracted to be manufactured during the 2023 calendar year. Vertiv products that contain 3TG minerals include Uninterruptible Power Supplies, DC Power Systems, and Thermal Management Products. Accordingly, we conducted a reasonable country of origin inquiry (“RCOI”) in good faith to determine whether the 3TG minerals may have originated in the DRC or Covered Countries. Based on the RCOI, Vertiv could not conclude that the 3TG minerals did not originate in the Covered Countries. Therefore, in accordance with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, Vertiv performed due diligence on the source and chain of custody of the 3TG minerals in question to determine whether such products are “DRC conflict-free” or responsibly sourced.
To assist with our RCOI, Vertiv retained Assent, a third-party service provider, to assist Vertiv with reviewing its supply chain and identifying risks. Vertiv analyzed its supply base from 2023 and selected suppliers that supplied material possibly containing 3TG minerals. Due to the extensive nature of Vertiv’s supply base, Vertiv narrowed its review and analysis to suppliers whose 2023 spend with Vertiv exceeded $10,000, which collectively represented 99.66% of Vertiv’s total direct materials expenditures for 2023. The analysis identified that 59.93% of Vertiv’s total direct material expenditures potentially contain 3TG minerals, and respective suppliers were asked to provide a Conflict Minerals Reporting Template (“CMRT”). Vertiv provided the list of suppliers whose products possibly contain 3TG minerals to Assent, and Assent conducted a survey of such suppliers using CMRT version 6.31, maintained by RMI.
Assent contacted the suppliers and requested that they complete the CMRT via its software-as-a-service (SaaS) platform, which facilitates communications and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. Each request was sent with a reminder that Vertiv’s Terms and Conditions of Purchase require that products supplied to Vertiv be associated only with RMAP Conformant or Active smelters as listed on the RMI website or with smelters certified to be conflict-free by other credible organizations. Consequently, Vertiv requires suppliers to work with the upstream supply chain on removing RMAP non-conformant, high-risk, and inactive smelters from the supply chain of products supplied to Vertiv. Training and educational material to guide suppliers on best practices and the use of the CMRT template was included. Assent assessed the quality of each supplier response and assigned a health score based on the supplier’s declaration.
Vertiv’s program includes automated data validation on all submitted CMRTs. The data validation is based on questions within the declaration sheet of the CMRT and aims to (i) increase the accuracy of submissions, (ii) identify any contradictory answers in the CMRT, (iii) help identify areas that require further classification or risk assessment, and (iv) understand the due diligence of Tier 1 suppliers. The data validation results are shared with the suppliers to ensure that they understand areas that require clarification or improvement. All submitted declaration forms are accepted so that data is retained, but they are classified as valid or invalid based on a set criteria of validation errors (see Annex C for CMRT validation criteria). Vertiv and/or Assent contacted suppliers with potentially invalid or incomplete CMRTs and encouraged them to submit or resubmit a valid response and provided guidance on how to correct errors via feedback to the CMRT submission, training courses, and direct engagement by Assent’s multilingual Supplier Experience team. Assent monitored and tracked all supplier responses and communications for reporting and transparency. Vertiv directly contacted unresponsive suppliers and requested they complete the CMRT and submit it to Assent or directly to Vertiv. Further, Vertiv tracks those suppliers that remain unresponsive to the campaign to allow for future improvement opportunities.
Based on data collected through May 21, 2024, 1050 suppliers within the conflict minerals program provided the CMRT. Vertiv’s conflict minerals program response rate is 93.10% representing 57.91% of our total direct material expenditures in 2023.
| | | | | | | | |
| Year | Supplier in Scope | Response Rate |
| 2021 | 960 | 75.63% |
| 2022 | 1126 | 81.44% |
| 2023 | 1128 | 93.10% |
Based on the data collected through May 21, 2024, 392 suppliers submitted an EMRT, representing 78.87% of the 497 suppliers in scope for the Cobalt Reporting program and 40.60% of our total direct material expenditures in 2023.
Through the reasonable due diligence practices, Vertiv has taken advantage of a broader set of country-of-origin data to complement efforts in establishing transparency in the supply chain. Based on the findings, Vertiv was able to identify countries from which minerals used in its products originated.
3.Due Diligence
Vertiv designed its due diligence measures to conform, in all material respects, to the five-step due diligence framework described in the Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, and the related supplements for gold, tin, tantalum and tungsten (the “OECD Guidance”). Vertiv continues to evaluate market expectations for data collection and reporting to achieve continuous improvement. Due diligence requires Vertiv to rely on data provided by direct suppliers and third-party audit programs. There is therefore a risk of incomplete or inaccurate data as the entire process is not, and cannot, be fully managed by Vertiv. However, through active risk identification, and risk assessment, as well as continued outreach and process validation, risk gaps can be mitigated. Vertiv’s due diligence process aligns with industry standards and market expectations for downstream company due diligence processes.
Vertiv integrated the five steps recommended by the OECD Guidance as follows:
a.Establishment of Company Management Systems
Vertiv established a cross-functional team to implement and manage our conflict minerals compliance program. The team, led by our global procurement organization, includes representatives from our product development, supply chain and legal departments. The team is responsible for implementing conflict minerals compliance strategies and briefing senior management about the results of our due diligence measures.
In addition, Vertiv has implemented the following:
i.Vertiv’s Conflict Minerals Statement, published on our website, that articulates Vertiv’s support for efforts to end the human suffering and environmental impact associated with mining in the DRC and Covered Countries.
ii.Vertiv’s Conflict Minerals Policy which reflects Vertiv’s commitment to support efforts to end human suffering and environmental impact that have been associated with mining of conflict minerals and cobalt in the DRC and Covered Countries. This policy further demonstrates Vertiv’s stance to conflict minerals use and sourcing to ensure compliance with applicable laws and regulations related to the supply of products which contain conflict minerals.
iii.Vertiv’s contracts with direct suppliers require the suppliers to trace and disclose information about the country of origin of minerals used in goods supplied to Vertiv. Vertiv relies on direct suppliers to provide information on the origin of the 3TG minerals contained in components and materials supplied, including sources of 3TG minerals that are supplied on them from lower-tier suppliers. Vertiv also has communicated its expectations to its suppliers regarding the existence of policies that result in avoidance of conflict minerals that are not DRC conflict-free in products
sold to Vertiv. Vertiv further expects all its suppliers to have policies and procedures in place that ensure that 3TG minerals used in products supplied to Vertiv are conflict-free or responsibly sourced. This means that the products should not contain 3TG minerals sourced from areas that have been identified to be in the presence of widespread human rights abuses or violations of law either directly or indirectly. The Supplier Code of Conduct communicates Vertiv’s commitment to sourcing consistent with the OECD Guidance or an equivalent, recognized due diligence framework and require suppliers source 3TG minerals and cobalt only from conflict-free smelters or refiners as recognized by RMI or similar recognized organization to ensure that products supplied to Vertiv do not support armed conflicts and human rights violations.
iv.Vertiv actively enforces its Code of Conduct and Supplier Code of Conduct, which outline expected behaviors for our employees, officers, directors and suppliers. All suppliers are expected to act in accordance with such documents and comply with product-related requirements, including conflict minerals reporting. Vertiv’s Code of Conduct and Supplier Code of Conduct are based on internationally accepted principles such as United Nations Guiding Principles on Business and Human Rights and the OECD Guidance. They are available on our website at: https://www.vertiv.com/en-us/about/ethics--compliance/
v.Vertiv established a helpline that allows employees and suppliers to report any suspected violations or concerns, including any suspected violations or concerns regarding our conflict minerals program, Code of Conduct, or Supplier Code of Conduct. Suppliers and Vertiv employees also can contact the Vertiv Conflict Minerals Team, including to report grievances via dedicated conflict minerals email address. Violations or grievances at the industry level can be reported to the RMI directly as well. This can be done at http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/
vi.Vertiv engaged Assent to assist with evaluating supply chain information regarding 3TG minerals, identifying potential risks, and developing additional due diligence steps that Vertiv may undertake with suppliers. Assent’s dedicated program specialists support Vertiv’s conflict minerals program and provide frequent updates to Vertiv. Each member of Assent’s Customer Success team is trained in conflict minerals compliance and understands the intricacies of the CMRT and conflict minerals reporting, as well as Section 1502 of the Dodd-Frank Act.
vii.Vertiv engaged with suppliers that refused to cooperate with Assent or were unresponsive to the request for a valid CMRT for products they supplied to Vertiv. With respect to OECD requirement to strengthen engagement with suppliers, Vertiv has developed an internal procedure that includes steps of supplier engagement escalation and adequate formal corrective action process. Direct supplier outreach includes several emails and reminders sent by dedicated Vertiv compliance analysts in cooperation with respective commodity managers who have been added to emails sent to suppliers so as to support negotiations with suppliers. Feedback from this engagement process allows Vertiv to ascertain opportunities for improvement in future conflict minerals campaigns.
viii.Vertiv, in cooperation with Assent, organized a training webinar where all suppliers in scope for Vertiv’s conflict minerals program were invited and trained on the OECD Due Diligence and 5 Step Framework principles. In cooperation with Assent, Vertiv further leveraged Assent’s online educational resources, and all of its suppliers have been provided with access to conflict minerals training materials, while all suppliers have access to a free platform for the CMRT submission. Furthermore, Assent’s automated feedback process notifies suppliers of risks associated with their CMRT submission, which serves to further educate suppliers of certain conflict minerals risks.
ix.Non-English-speaking suppliers are included in Vertiv initiatives and have access to multilingual help desk support and other resources via Assent. This permits all suppliers worldwide to access Vertiv’s platform for CMRT uploads and correspondence.
x.In response to specific customer requests, Vertiv engaged directly with specific suppliers to obtain valid conflict-free CMRT reports and documentation.
xi.Vertiv retains the collected conflict minerals related data through Assent. All CMRTs, supplier responses, campaign-related data as well as findings and reports are retained in the ASM system and can be audited by internal or external parties.
Vertiv believes that the combination of Assent services with strong internal policies and direct Vertiv involvement in communication with suppliers constitute a strong supplier engagement program.
b.Identify and Assess Risks in the Supply Chain
As stated above, Vertiv is a member of RMI and has adopted the RMI’s approach to identifying and assessing risks in its supply chain. In applying this approach, we conducted due diligence to trace the origin of 3TG minerals provided to us by identifying smelters, refiners or recyclers, and scrap supplier sources in our supply chain.
Vertiv, through Assent, verified the information provided by our suppliers through the CMRT for completeness and consistency of responses. Where we identified inaccuracies, we required the suppliers to correct the errors and submit an updated CMRT or to provide additional information.
Identified risks at supplier level include non-responsive suppliers, incomplete CMRTs, and CMRTs providing smelter data beyond coverage of products supplied solely to Vertiv. Vertiv is unable to determine if all smelters and refiners listed in company-level CMRTs provided by suppliers are connected to products supplied to Vertiv. Additionally, some suppliers indicated that they cannot provide comprehensive list of smelters used in their supply chain due to limits in information provided by lower tier suppliers.
Suppliers were further assesed based on their program’s strength. The criteria used to evaluate the strength of the program were based on certain questions in the CMRT related to suppliers’ conflict minerals practices.
Other supply chain risks were identified by assessing the due diligence practices and audit status of smelters and refiners identified in the supplied CMRTs. Assent’s smelter validation program compared listed facilities to the list of smelters and refiners consolidated by RMI to ensure that the facilities met the recognized definition of a 3TG minerals processing facility which was operational in 2023.
Assent confirmed the validation status of the smelters and refiners reported by our suppliers by determining if such entities had been audited against a standard in conformance with the OECD Guidance, such as the Responsible Minerals Assurance Process (RMAP). Vertiv does not have direct relationships with smelters and refiners and does not perform direct audits of these entities within their pre-supply chain. Smelters and refiners that have completed an RMAP audit are considered to have their sourcing validated as “conflict free or responsibly sourced”. Smelters and refiners are actively monitored to proactively identify the risk pertaining to conflict minerals.
Each facility that meets the definition of a smelter or refiner of 3TG minerals was assessed according to red flag indicators defined in the OECD Guidance. Assent used several factors to measure sourcing risk, including:
•Geographic proximity to the DRC and Covered Countries
•Known mineral source country of origin
•RMAP audit status
•Credible evidence of unethical or conflict sourcing
•Peer assessments conducted by credible third-party sources
•Sanctions risks
Vertiv initiated risk mitigation efforts where a supplier’s CMRT reported facilities of concern, including instructing the supplier to undertake its own independent risk mitigation actions and asking the supplier to submit a product-specific or user defined CMRT to Vertiv identifying the connection, if any, between the facilities of concern and 3TG minerals supplied to Vertiv. Vertiv provided suppliers with clear performance objectives within reasonable timeframes, with the ultimate goal of progressively eliminating facilities of concern from Vertiv’s supply chain. Vertiv asked suppliers to prioritize the elimination of smelters and refiners of high concern as identified by Assent’s “Smelter of Interest Guide” due to their affiliations to sanctions lists or suspicion of connection to human rights violations. We continue to work with our suppliers to identify and address legacy material sourced from high-risk or now sanctioned sources that remain in the global supply chain. If suppliers refused to cooperate, the issue has been escalated to respective commodity managers and suppliers were reminded of their contractual duties to Vertiv’s commitment to responsible sourcing.
For the suppliers that provided country-of-origin information for 3TG minerals, we confirmed the listed countries of origin for each smelter and refiner if the information was available from RMI. Some suppliers identified missing information from their supply chains and therefore could not provide a complete list of their upstream smelters and refiners.
c. Design and Implement a Strategy to Respond to Identified Risks
Vertiv has developed and implemented processes to assess and respond to the risks identified in the supply chain. Vertiv has a risk management plan through which the conflict minerals program is implemented, managed, and monitored. Vertiv responds to identified risks by enforcing our Supplier Code of Conduct and Purchase Order Terms and Conditions. Both documents communicate to our suppliers our expectations and requirements relating to the use and sourcing of 3TG minerals. Specifically, Vertiv’s Terms and Conditions of Purchase require our suppliers to trace and declare the country of origin of minerals used in all materials and to promptly provide Vertiv with relevant CMRT reports upon request. In support of conflict-free conflict minerals sourcing, Vertiv’s Terms and Conditions of Purchase further require Vertiv suppliers to source conflict minerals only from conflict-free smelters and refiners, regardless of where the smelter or refiner is located. Through its membership in RMI and cooperation with Assent, Vertiv supports multistakeholder responsible sourcing efforts and supports development and implementation of responsible sourcing practices.
Suppliers that are either non-responsive, provide incomplete or inconsistent responses to Vertiv’s solicitations for information or do not respond to Vertiv’s enhanced smelter due diligence are escalated within Vertiv’s procurement organization for follow-up and receive email communications reminding them of the importance of a response via CMRT and of Vertiv’s expectations relating to the use and sourcing of 3TG minerals.
In response to identified risks, Vertiv established the Vertiv Enhanced Smelter Due Diligence program, through which Vertiv followed up with every supplier that reported other non-RMI conformant and active smelters. Suppliers were contacted in accordance with the OECD Guidance to inform them of the potential risk, and to evaluate whether these smelters could be connected to Vertiv’s products. If confirmed, Vertiv requested these suppliers remove all non-RMI conformant or active smelters and refiners from the supply chain of products supplied to Vertiv. The suppliers were asked to complete user-defined or product-level CMRT specific to materials, products, or piece of parts purchased by Vertiv.
Suppliers receive feedback on their submissions and access to educational resources to assist suppliers in corrective action methods or to improve their internal programs. In cases where suppliers have continuously been non-responsive or are not committed to corrective action plans, Vertiv will assess if replacing that supplier is feasible.
The Global Procurement Compliance team regularly reports to Vertiv’s procurement leadership, Chief Procurement Officer and Global Compliance Officer on its efforts to collect CMRTs, the conflict-free status of suppliers, and the findings of the supply chain risk assessment.
d. Independent Third-Party Audits of Supply Chain Due Diligence
As a downstream company, Vertiv does not have a direct relationship with smelters or refiners, and we do not perform or direct audits of smelters or refiners. Vertiv relies on third-party audits of smelters and refiners conducted as a part of the RMAP and results of such audits made available by RMI. Assent followed up with suppliers reporting smelters or refiners that are not currently enrolled in an industry recognized audit/assessment program to encourage their
participation and gather information regarding each facilities’ sourcing practices. Furthermore, Vertiv is a signatory of Assent’s communication to smelters and refiners who participated in RMAP and are conformant to the corresponding program’s standards to express Vertiv’s gratitude for ethical minerals sourcing in accordance with the requirements of downstream companies detailed in OECD Guidance. Through Vertiv’s membership with the RMI, smelters and refiners have been encouraged to participate in the RMAP as well.
e. Report on Supply Chain Due Diligence
Vertiv reports annually on its conflict minerals due diligence program in this Report, which is filed annually with the Securities and Exchange Commission. This Report is available on the Ethics and Compliance section of the Vertiv’s company website at https://www.vertiv.com/en-us/about/ethics--compliance/#/tab-supply-chain.
4.Results of Our Reasonable Country of Origin Inquiry and Due Diligence
For the reporting period of January 1, 2023 through December 31, 2023, Vertiv solicited 1,128 in-scope suppliers to gather detailed information regarding the existence of 3TG minerals in components and materials sold to us, as well as the origin and chain of custody of such 3TG minerals. Based on the information provided by our suppliers and our own due diligence efforts, as described in this Report, through May 21, 2024, we do not have sufficient information to conclusively determine the countries of origin or chain of custody of all 3TG minerals in our products. Annex A to this Report lists those smelters and refiners that were operational in calendar year 2023, met the recognized definition of 3TG minerals processing facility and may have been used to process 3TG minerals in Vertiv’s supply chain. Annex B lists the countries of origin of these 3TG minerals, based on reasonable country of origin data obtained via Assent’s supply chain database. Due to the common practice of the collection of company-level CMRTs among suppliers, and inability of upstream suppliers to discern exactly which company’s product lines are connected to a particular smelter or refiner, the list of smelters and refiners that processed 3TG minerals used in Vertiv products, as well as the list of countries of origin of the 3TG minerals, are likely to be more comprehensive than the list of smelters and refiners and their respective countries of origin that actually processed the 3TG minerals contained in Vertiv’s products.
Taking into account this potential over-reporting, Vertiv has taken measures to validate all smelter and refiner data against validated audit program and databases intended to verify potentially high-risk smelters. All suppliers who reported smelters that potentially posed a risk due to the presence of red flag indicators were contacted in accordance with the OECD Guidance as stipulated in the previous sections and asked to provide more specific CMRT. While 61.24% of suppliers were able to provide conflict-free CMRT other suppliers need more time to process Vertiv’s request for conflict free sourcing and therefore Vertiv’s Conflict Minerals Report for 2023 includes several smelters which do not have RMI conformant or active status. All suppliers that didn’t provide the conflict free CMRT by Vertiv’s stated deadline for the Report shall be warned that they need to improve their due diligence in the next reporting period.
The tables below summarize the quantity of smelters and refiners and source of 3TG minerals reported in the CMRTs submitted by Vertiv´s suppliers who responded to our Conflict Minerals campaign for reporting year 2023:
| | | | | | | | | | | | | | | | | |
| Conflict Mineral | RMAP Conformant | RMAP
Active | Non-enrolled | Non-Conformant | Total |
| Tin | 67 | 3 | 10 | 8 | 88 |
| Tantalum | 34 | 0 | 2 | 0 | 36 |
| Tungsten | 34 | 1 | 16 | 4 | 55 |
| Gold | 90 | 5 | 65 | 17 | 177 |
| | | | | | | | | | | | | | | | | |
| Source of 3TG Mineral | RMAP Conformant | RMAP
Active | Non-enrolled | Non-Conformant | Total |
| 3TG mineral sourced from DRC or adjoining country | 56 | 0 | 15 | 6 | 77 |
| 3TG mineral not sourced from DRC or adjoining country | 156 | 3 | 56 | 23 | 238 |
| Unknown | 13 | 6 | 22 | 0 | 41 |
5.Risk Mitigation
Vertiv intends to continue evaluating its RCOI and due diligence processes in accordance with the provisions of the Rule to further mitigate the risk that 3TG minerals necessary to our products benefit armed groups or conflicts. In particular, we intend to:
a.Continue working with suppliers willing to support Vertiv’s dedication to principles of the ethical sourcing;
b.Request suppliers source 3TG minerals only from smelters and refiners that are conformant or active in the RMI’s Responsible Minerals Assurance Process;
c.Further strengthen engagement with suppliers, provide information and training resources regarding responsible sourcing of 3TG minerals and the importance of conflict-free sourcing to allow Vertiv to improve the quantity and quality of information received during our due diligence processes;
d.Continue to include the requirement for conflict minerals reporting and conflict-free sourcing in Vertiv’s Supplier Code of Conduct, General Terms and Conditions of Purchase and implement it within its Master Purchase Agreement forms;
e.Remain aware of developments in conflict minerals due diligence processes through Vertiv’s membership in RMI, expanding our participation in its initiatives and applying its principles to Vertiv’s conflict minerals program;
f.Continue to evaluate upstream resources through a broader set of tools to evaluate risks. These include, but are not limited to the use of a comprehensive smelter and refiner database with detailed statuses, and comparing the list of smelters and refiners against government watch and denied parties lists.
ANNEX A
Table 1 below lists smelters and refiners from Vertiv’s 3TG minerals RCOI. Please note that some of the listed smelters and refiners may not actually provide 3TG minerals to be used in Vertiv products because the smelters and refiners may have declared 3TG minerals only as part of a company-level CMRT submission, rather than a CMRT specific to the products supplied to Vertiv. However, Vertiv is listing these smelters and refiners in the interest of presenting a complete list.
Table 1. Smelters and refiners reported in Vertiv CMRT.
| | | | | | | | |
| Mineral | Smelter / Refiner Name | Facility Location |
| Gold | Advanced Chemical Company | United States Of America |
| Gold | Aida Chemical Industries Co., Ltd. | Japan |
| Gold | Agosi AG | Germany |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil |
| Gold | Argor-Heraeus S.A. | Switzerland |
| Gold | Asahi Pretec Corp. | Japan |
| Gold | Asaka Riken Co., Ltd. | Japan |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey |
| Gold | Aurubis AG | Germany |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines |
| Gold | Boliden AB | Sweden |
| Gold | C. Hafner GmbH + Co. KG | Germany |
| Gold | Caridad | Mexico |
| Gold | CCR Refinery - Glencore Canada Corporation | Canada |
| Gold | Cendres + Metaux S.A. | Switzerland |
| Gold | Yunnan Copper Industry Co., Ltd. | China |
| Gold | Chimet S.p.A. | Italy |
| Gold | Chugai Mining | Japan |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China |
| Gold | DSC (Do Sung Corporation) | Korea, Republic Of |
| Gold | Dowa | Japan |
| Gold | Eco-System Recycling Co., Ltd. East Plant | Japan |
| Gold | JSC Novosibirsk Refinery | Russian Federation |
| Gold | Refinery of Seemine Gold Co., Ltd. | China |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China |
| Gold | LT Metal Ltd. | Korea, Republic Of |
| Gold | Heimerle + Meule GmbH | Germany |
| Gold | Heraeus Metals Hong Kong Ltd. | China |
| Gold | Heraeus Germany GmbH Co. KG | Germany |
| Gold | Hunan Chenzhou Mining Co., Ltd. | China |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China |
| Gold | HwaSeong CJ CO., LTD. | Korea, Republic Of |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China |
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan |
| | | | | | | | |
| Gold | Istanbul Gold Refinery | Turkey |
| Gold | Japan Mint | Japan |
| Gold | Jiangxi Copper Co., Ltd. | China |
| Gold | Asahi Refining USA Inc. | United States Of America |
| Gold | Asahi Refining Canada Ltd. | Canada |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation |
| Gold | JSC Uralelectromed | Russian Federation |
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan |
| Gold | Kazakhmys Smelting LLC | Kazakhstan |
| Gold | Kazzinc | Kazakhstan |
| Gold | Kennecott Utah Copper LLC | United States Of America |
| Gold | Kojima Chemicals Co., Ltd. | Japan |
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan |
| Gold | L'azurde Company For Jewelry | Saudi Arabia |
| Gold | Lingbao Gold Co., Ltd. | China |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China |
| Gold | LS-NIKKO Copper Inc. | Korea, Republic Of |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China |
| Gold | Materion | United States Of America |
| Gold | Matsuda Sangyo Co., Ltd. | Japan |
| Gold | Metalor Technologies (Suzhou) Ltd. | China |
| Gold | Metalor Technologies (Hong Kong) Ltd. | China |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore |
| Gold | Metalor Technologies S.A. | Switzerland |
| Gold | Metalor USA Refining Corporation | United States Of America |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico |
| Gold | Mitsubishi Materials Corporation | Japan |
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan |
| Gold | Moscow Special Alloys Processing Plant | Russian Federation |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey |
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan |
| Gold | Nihon Material Co., Ltd. | Japan |
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation |
| Gold | MKS PAMP SA | Switzerland |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China |
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation |
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia |
| Gold | PX Precinox S.A. | Switzerland |
| Gold | Rand Refinery (Pty) Ltd. | South Africa |
| Gold | Royal Canadian Mint | Canada |
| Gold | Sabin Metal Corp. | United States Of America |
| Gold | Samduck Precious Metals | Korea, Republic Of |
| Gold | Samwon Metals Corp. | Korea, Republic Of |
| | | | | | | | |
| Gold | SEMPSA Joyeria Plateria S.A. | Spain |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation |
| Gold | Solar Applied Materials Technology Corp. | Taiwan, Province Of China |
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan |
| Gold | Super Dragon Technology Co., Ltd. | Taiwan, Province Of China |
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China |
| Gold | Shandong Gold Smelting Co., Ltd. | China |
| Gold | Tokuriki Honten Co., Ltd. | Japan |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | China |
| Gold | Torecom | Korea, Republic Of |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium |
| Gold | United Precious Metal Refining, Inc. | United States Of America |
| Gold | Valcambi S.A. | Switzerland |
| Gold | Western Australian Mint (T/a The Perth Mint) | Australia |
| Gold | Yamakin Co., Ltd. | Japan |
| Gold | Yokohama Metal Co., Ltd. | Japan |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China |
| Gold | Morris and Watson | New Zealand |
| Gold | SAFINA A.S. | Czechia |
| Gold | Guangdong Jinding Gold Limited | China |
| Gold | Umicore Precious Metals Thailand | Thailand |
| Gold | MMTC-PAMP India Pvt., Ltd. | India |
| Gold | KGHM Polska Miedz Spolka Akcyjna | Poland |
| Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe |
| Gold | Singway Technology Co., Ltd. | Taiwan, Province Of China |
| Gold | Shandong Humon Smelting Co., Ltd. | China |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | China |
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates |
| Gold | Emirates Gold DMCC | United Arab Emirates |
| Gold | International Precious Metal Refiners | United Arab Emirates |
| Gold | Kaloti Precious Metals | United Arab Emirates |
| Gold | Sudan Gold Refinery | Sudan |
| Gold | T.C.A S.p.A | Italy |
| Gold | REMONDIS PMR B.V. | Netherlands |
| Gold | Fujairah Gold FZC | United Arab Emirates |
| Gold | Industrial Refining Company | Belgium |
| Gold | Shirpur Gold Refinery Ltd. | India |
| Gold | Korea Zinc Co., Ltd. | Korea, Republic Of |
| Gold | Marsam Metals | Brazil |
| Gold | TOO Tau-Ken-Altyn | Kazakhstan |
| | | | | | | | |
| Gold | Abington Reldan Metals, LLC | United States Of America |
| Gold | Shenzhen CuiLu Gold Co., Ltd. | China |
| Gold | Albino Mountinho Lda. | Portugal |
| Gold | SAAMP | France |
| Gold | L'Orfebre S.A. | Andorra |
| Gold | 8853 S.p.A. | Italy |
| Gold | Italpreziosi | Italy |
| Gold | WIELAND Edelmetalle GmbH | Germany |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria |
| Gold | AU Traders and Refiners | South Africa |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | India |
| Gold | Sai Refinery | India |
| Gold | Modeltech Sdn Bhd | Malaysia |
| Gold | Bangalore Refinery | India |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany |
| Gold | Pease & Curren | United States Of America |
| Gold | JALAN & Company | India |
| Gold | SungEel HiMetal Co., Ltd. | Korea, Republic Of |
| Gold | Planta Recuperadora de Metales SpA | Chile |
| Gold | ABC Refinery Pty Ltd. | Australia |
| Gold | Safimet S.p.A | Italy |
| Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania |
| Gold | African Gold Refinery | Uganda |
| Gold | Gold Coast Refinery | Ghana |
| Gold | NH Recytech Company | Korea, Republic Of |
| Gold | QG Refining, LLC | United States Of America |
| Gold | Dijllah Gold Refinery FZC | United Arab Emirates |
| Gold | CGR Metalloys Pvt Ltd. | India |
| Gold | Sovereign Metals | India |
| Gold | Eco-System Recycling Co., Ltd. North Plant | Japan |
| Gold | Eco-System Recycling Co., Ltd. West Plant | Japan |
| Gold | Augmont Enterprises Private Limited | India |
| Gold | Kundan Care Products Ltd. | India |
| Gold | Emerald Jewel Industry India Limited (Unit 1) | India |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | India |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | India |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | India |
| Gold | K.A. Rasmussen | Norway |
| Gold | Alexy Metals | United States Of America |
| Gold | MD Overseas | India |
| Gold | Metallix Refining Inc. | United States Of America |
| Gold | Metal Concentrators SA (Pty) Ltd. | South Africa |
| Gold | WEEEREFINING | France |
| | | | | | | | |
| Gold | Gold by Gold Colombia | Colombia |
| Gold | Dongwu Gold Group | China |
| Gold | Sam Precious Metals | United Arab Emirates |
| Gold | Coimpa Industrial LTDA | Brazil |
| Gold | GG Refinery Ltd. | Tanzania, United Republic Of |
| Gold | SHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD. | China |
| Gold | Impala Refineries – Base Metals Refinery (BMR) | South Africa |
| Gold | Impala Rustenburg | South Africa |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | China |
| Tantalum | F&X Electro-Materials Ltd. | China |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | China |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China |
| Tantalum | Jiujiang Tanbre Co., Ltd. | China |
| Tantalum | AMG Brasil | Brazil |
| Tantalum | Metallurgical Products India Pvt., Ltd. | India |
| Tantalum | Mineracao Taboca S.A. | Brazil |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan |
| Tantalum | NPM Silmet AS | Estonia |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China |
| Tantalum | QuantumClean | United States Of America |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China |
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation |
| Tantalum | Taki Chemical Co., Ltd. | Japan |
| Tantalum | Telex Metals | United States Of America |
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China |
| Tantalum | D Block Metals, LLC | United States Of America |
| Tantalum | FIR Metals & Resource Ltd. | China |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China |
| Tantalum | KEMET de Mexico | Mexico |
| Tantalum | TANIOBIS Co., Ltd. | Thailand |
| Tantalum | TANIOBIS GmbH | Germany |
| Tantalum | Materion Newton Inc. | United States Of America |
| Tantalum | TANIOBIS Japan Co., Ltd. | Japan |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | Germany |
| Tantalum | Global Advanced Metals Boyertown | United States Of America |
| Tantalum | Global Advanced Metals Aizu | Japan |
| Tantalum | Resind Industria e Comercio Ltda. | Brazil |
| Tantalum | Jiangxi Tuohong New Raw Material | China |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | China |
| Tantalum | 5D Production OU | Estonia |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China |
| Tantalum | PowerX Ltd. | Rwanda |
| | | | | | | | |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China |
| Tin | Alpha | United States Of America |
| Tin | PT Aries Kencana Sejahtera | Indonesia |
| Tin | PT Premium Tin Indonesia | Indonesia |
| Tin | Dowa | Japan |
| Tin | EM Vinto | Bolivia (Plurinational State Of) |
| Tin | Estanho de Rondonia S.A. | Brazil |
| Tin | Fenix Metals | Poland |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | China |
| Tin | Gejiu Kai Meng Industry and Trade LLC | China |
| Tin | China Tin Group Co., Ltd. | China |
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia |
| Tin | Metallic Resources, Inc. | United States Of America |
| Tin | Mineracao Taboca S.A. | Brazil |
| Tin | Minsur | Peru |
| Tin | Mitsubishi Materials Corporation | Japan |
| Tin | Jiangxi New Nanshan Technology Ltd. | China |
| Tin | Novosibirsk Tin Combine | Russian Federation |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand |
| Tin | Operaciones Metalurgicas S.A. | Bolivia (Plurinational State Of) |
| Tin | PT Artha Cipta Langgeng | Indonesia |
| Tin | PT Babel Inti Perkasa | Indonesia |
| Tin | PT Babel Surya Alam Lestari | Indonesia |
| Tin | PT Bangka Tin Industry | Indonesia |
| Tin | PT Belitung Industri Sejahtera | Indonesia |
| Tin | PT Bukit Timah | Indonesia |
| Tin | PT Mitra Stania Prima | Indonesia |
| Tin | PT Panca Mega Persada | Indonesia |
| Tin | PT Prima Timah Utama | Indonesia |
| Tin | PT Refined Bangka Tin | Indonesia |
| Tin | PT Sariwiguna Binasentosa | Indonesia |
| Tin | PT Stanindo Inti Perkasa | Indonesia |
| Tin | PT Timah Tbk Kundur | Indonesia |
| Tin | PT Timah Tbk Mentok | Indonesia |
| Tin | PT Timah Nusantara | Indonesia |
| Tin | PT Tinindo Inter Nusa | Indonesia |
| Tin | PT Tommy Utama | Indonesia |
| Tin | Rui Da Hung | Taiwan, Province Of China |
| Tin | Thaisarco | Thailand |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China |
| Tin | VQB Mineral and Trading Group JSC | Viet Nam |
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | China |
| | | | | | | | |
| Tin | CV Venus Inti Perkasa | Indonesia |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil |
| Tin | PT Tirus Putra Mandiri | Indonesia |
| Tin | Melt Metais e Ligas S.A. | Brazil |
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia |
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines |
| Tin | CV Ayi Jaya | Indonesia |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam |
| Tin | PT Rajehan Ariq | Indonesia |
| Tin | PT Cipta Persada Mulia | Indonesia |
| Tin | An Vinh Joint Stock Mineral Processing Company | Viet Nam |
| Tin | Resind Industria e Comercio Ltda. | Brazil |
| Tin | Super Ligas | Brazil |
| Tin | Aurubis Beerse | Belgium |
| Tin | Aurubis Berango | Spain |
| Tin | PT Bangka Prima Tin | Indonesia |
| Tin | PT Sukses Inti Makmur | Indonesia |
| Tin | PT Menara Cipta Mulia | Indonesia |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | China |
| Tin | Modeltech Sdn Bhd | Malaysia |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China |
| Tin | PT Bangka Serumpun | Indonesia |
| Tin | Pongpipat Company Limited | Myanmar |
| Tin | Tin Technology & Refining | United States Of America |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | China |
| Tin | PT Rajawali Rimba Perkasa | Indonesia |
| Tin | Luna Smelter, Ltd. | Rwanda |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China |
| Tin | Precious Minerals and Smelting Limited | India |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China |
| Tin | PT Mitra Sukses Globalindo | Indonesia |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil |
| Tin | CRM Synergies | Spain |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil |
| Tin | DS Myanmar | Myanmar |
| Tin | PT Putera Sarana Shakti (PT PSS) | Indonesia |
| Tin | Mining Minerals Resources SARL | Congo, Democratic Republic Of The |
| Tin | Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. | Japan |
| Tin | Malaysia Smelting Corporation Berhad (Port Klang) | Malaysia |
| | | | | | | | |
| Tungsten | A.L.M.T. Corp. | Japan |
| Tungsten | Kennametal Huntsville | United States Of America |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | China |
| Tungsten | Global Tungsten & Powders LLC | United States Of America |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China |
| Tungsten | Hunan Jintai New Material Co., Ltd. | China |
| Tungsten | Japan New Metals Co., Ltd. | Japan |
| Tungsten | Kennametal Fallon | United States Of America |
| Tungsten | Wolfram Bergbau und Hutten AG | Austria |
| Tungsten | Xiamen Tungsten Co., Ltd. | China |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Viet Nam |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | China |
| Tungsten | H.C. Starck Tungsten GmbH | Germany |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | Germany |
| Tungsten | Masan High-Tech Materials | Viet Nam |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China |
| Tungsten | Niagara Refining LLC | United States Of America |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | China |
| Tungsten | Hydrometallurg, JSC | Russian Federation |
| Tungsten | Unecha Refractory metals plant | Russian Federation |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines |
| Tungsten | ACL Metais Eireli | Brazil |
| Tungsten | Moliren Ltd. | Russian Federation |
| Tungsten | Lianyou Metals Co., Ltd. | Taiwan, Province Of China |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation |
| Tungsten | NPP Tyazhmetprom LLC | Russian Federation |
| Tungsten | Hubei Green Tungsten Co., Ltd. | China |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil |
| Tungsten | Cronimet Brasil Ltda | Brazil |
| Tungsten | Artek LLC | Russian Federation |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | China |
| Tungsten | OOO “Technolom” 2 | Russian Federation |
| Tungsten | OOO “Technolom” 1 | Russian Federation |
| | | | | | | | |
| Tungsten | LLC Vostok | Russian Federation |
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | China |
| Tungsten | HANNAE FOR T Co., Ltd. | Korea, Republic Of |
| Tungsten | DONGKUK INDUSTRIES CO., LTD. | Korea, Republic Of |
| Tungsten | Tungsten Vietnam Joint Stock Company | Viet Nam |
| Tungsten | Nam Viet Cromit Joint Stock Company | Viet Nam |
| Tungsten | Lianyou Resources Co., Ltd. | Taiwan, Province Of China |
| Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. | China |
| Tungsten | Kenee Mining Corporation Vietnam | Viet Nam |
| Tungsten | MALAMET SMELTING SDN. BHD. | Malaysia |
| Tungsten | Philippine Carreytech Metal Corp. | Philippines |
ANNEX B
Table 2 below is an aggregate list of countries of origin from which the reported facilities collectively source 3TG minerals, based on reasonable country-of-origin data obtained via Assent’s supply chain database. As stated above, some smelters and refiners may have been declared as part of a company-level CMRT submission, rather than a CMRT specific to the products supplied to Vertiv. Therefore, Table 2 may list more countries than those which are the actual sources of 3TG minerals for Vertiv products.
Table 2. Countries of Origin of Conflict Minerals.
| | |
| Albania |
| Andorra |
| Angola |
| Argentina |
| Armenia |
| Australia |
| Austria |
| Azerbaijan |
| Belarus |
| Belgium |
| Benin |
| Bermuda |
| Bolivia (Plurinational State of) |
| Botswana |
| Brazil |
| Bulgaria |
| Burkina Faso |
| Burundi |
| Cambodia |
| Canada |
| Central African Republic |
| Chile |
| China |
| Colombia |
| Congo |
| Cyprus |
| Democratic Republic of Congo |
| Djibouti |
| Dominica |
| Dominican Republic |
| Ecuador |
| Egypt |
| El Salvador |
| Eritrea |
| Estonia |
| Ethiopia |
| Fiji |
| | |
| Finland |
| France |
| Georgia |
| Germany |
| Ghana |
| Guam |
| Guatemala |
| Guinea |
| Guyana |
| Honduras |
| Hong Kong |
| Hungary |
| India |
| Indonesia |
| Ireland |
| Israel |
| Italy |
| Ivory Coast |
| Japan |
| Jersey |
| Kazakhstan |
| Kenya |
| Korea |
| Kyrgyzstan |
| Liberia |
| Liechtenstein |
| Lithuania |
| Luxembourg |
| Madagascar |
| Malaysia |
| Mali |
| Mauritania |
| Mexico |
| Mongolia |
| Morocco |
| Mozambique |
| Myanmar |
| Namibia |
| Netherlands |
| New Zealand |
| Nicaragua |
| Niger |
| Nigeria |
| Norway |
| Oman |
| | |
| Panama |
| Papua New Guinea |
| Peru |
| Philippines |
| Poland |
| Portugal |
| Russian Federation |
| Rwanda |
| Saudi Arabia |
| Senegal |
| Serbia |
| Sierra Leone |
| Singapore |
| Slovakia |
| Solomon Islands |
| South Africa |
| South Sudan |
| Spain |
| Sudan |
| Suriname |
| Sweden |
| Switzerland |
| Taiwan |
| Tajikistan |
| Tanzania |
| Thailand |
| Togo |
| Turkey |
| Uganda |
| United Arab Emirates |
| United Kingdom |
| United States of America |
| Uruguay |
| Uzbekistan |
| VietNam |
| Zambia |
ANNEX C
The following table maps the Assent Sustainability Platform’s status and CMRT logic structure when determining supplier status in Vertiv’s conflict minerals program based on the answers provided in the CMRT by suppliers.
| | | | | |
| Supplier Status | Description |
| Not Submitted | Supplier was approached, a CMRT has not been submitted |
| Complete | Supplier submitted valid and complete CMRT |
| Incomplete | Supplier submitted partially completed CMRT not covering all products associated to them |
| Invalid | Supplier provided CMRT with contradictory answers |
| Out of Scope | Supplier is out of scope for the conflict minerals program and does not have to submit the CMRT |
